INTERNATIONAL DATA TRANSFERS INVOLVING THE EUROPEAN ECONOMIC AREA (“EEA”)

If you are in the EEA, the data that we collect from you as described in this Privacy Policy may be transferred to and stored at a destination outside the EEA in order to facilitate our business. Countries outside the EEA may not have laws which provide the same level of protection to your Personal Data as laws for EEA-member countries. Where this is the case we will attempt to implement appropriate safeguards to ensure that such transfers comply with EU Privacy Law by using standard contractual clauses approved by the European Commission as ensuring an adequate protection or by ensuring that the transfer is done to an organization that complies with Privacy Shield in case data transfer is made to the United States.

In this respect, please note that we adhere to the E.U.-U.S. and Swiss-U.S. Privacy Shield Framework. In compliance with the E.U.-U.S. and Swiss-U.S. Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your Personal Data. We have further committed to refer unresolved privacy complaints under the E.U.-U.S. and Swiss-U.S. Privacy Shields to the American Arbitration Association, http://go.adr.org/privacyshield.html. In certain limited cases, it may be possible for individuals to invoke binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission. Please note that if you are not a European Union or Switzerland resident, then Privacy Shield requirements regarding the handling of complaints may not apply to you and Privacy Shield enforcement mechanisms may not be available to you. In case you wish to obtain more details about our data transfer safeguards and the mechanisms in place, you may contact us at privacyquestion@esscoincorporated.com.

YOUR RIGHTS – NON-EU USERS

Depending on where you are located, you will have different rights in respect of your Personal Data and we will make every effort to comply with the relevant requirements of applicable laws and this Privacy Policy.

YOUR RIGHTS – EU USERS

If you are in the EU, you should know that the EU Privacy Law grants specific rights, summarized below, which you can in principle exercise free of charge, subject to statutory exceptions. These rights may be limited, for example if fulfilling your request would reveal Personal Data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. To exercise any of your rights, you can file a request via email at privacyquestion@esscoincorporated.com.

Should you have unresolved concerns, you have the right to lodge a complaint where you live or where you believe a breach may have occurred. We encourage you to come to us in the first instance but, to the extent that this right applies to you, you are entitled to complain directly to the relevant supervisory authority.

1. RIGHT TO WITHDRAW CONSENT

Wherever we rely on your consent, you will be able to withdraw that consent at any time you choose and at your own initiative by logging in to your account on our website (if you have one) or by contacting us at privacyquestion@esscoincorporated.com. The withdrawal of your consent will not affect the lawfulness of the collection and processing of your data based on your consent up until the moment where you withdraw your consent. Please note that we may have other legal grounds for processing your data for other purposes, such as those set out in this Privacy Policy.

2. RIGHT TO ACCESS AND RECTIFY YOUR DATA

You have the right to access, review, and rectify your Personal Data. You may be entitled to ask us for a copy of your information, to review or correct it if you wish to rectify any information like your name, email address, passwords and/or any other preferences, you can easily do so by logging in to your account on our website (if you have one) or by contacting us at privacyquestion@esscoincorporated.com. You may also request a copy of the Personal Data processed as described in this Privacy Policy.

3. RIGHT TO ERASURE

In accordance with EU Privacy Law, you have the right to erasure of your Personal Data processed by us as described in this Privacy Policy in case it is no longer needed for the purposes for which the Personal Data was initially collected or processed or in the event you have withdrawn your consent or objected to processing as described in this Privacy Policy and no other legal ground for processing applies. Should you wish to have your Personal Data erased, please file a request via email at privacyquestion@esscoincorporated.com.

4. RIGHT TO RESTRICTION OF PROCESSING

Under certain circumstances described in EU Privacy Law, you may ask us to restrict the processing of your Personal Data. This is for example the case when you contest the accuracy of your Personal Data. In such event, we will restrict the processing until we can verify the accuracy of your data.

5. RIGHT TO OBJECT TO PROCESSING

Under certain circumstances described in EU Privacy Law, you may object to the processing of your Personal Data, including where your Personal Data is processed for direct marketing purposes.

6. RIGHT TO DATA PORTABILITY

Where you have provided your data directly to us and where the processing is carried out by automated means and based on your consent or the performance of a contract between you and us, you have the right to receive the Personal Data processed about you in a structured, commonly used and machine-readable format, and to transmit this data to another service provider.